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Patrick Traylor

Patrick Traylor Partner, Environmental & Natural Resources

Companies around the world have turned to Patrick for almost twenty-five years to represent them in environmental enforcement cases and to conduct their most sensitive internal environmental compliance investigations. Most recently, Patrick was the Deputy Assistant Administrator for the U.S. Environmental Protection Agency’s Office of Enforcement and Compliance Assurance (OECA), where he served as one of the highest-ranking environmental enforcement attorneys in the federal government.

During his tenure at the EPA, Patrick supervised the agency’s nationwide Clean Air Act (CAA) civil enforcement docket. He was also integrally involved in the development of every significant enforcement policy and represented OECA in reviewing all CAA regulations and guidance issued by the EPA. Patrick leverages this insight into the EPA’s CAA enforcement process to effectively and efficiently represent clients facing enforcement investigations and actions.

In addition to his litigation practice, companies in the energy sector have turned to Patrick to secure project-critical environmental approvals for the construction and expansion of tens of billions of dollars’ worth of projects at refineries, petrochemical and fertilizer plants, LNG export terminals, and coal- and gas-fired power plants.

In his environmental enforcement practice, Patrick’s clients value his thorough preparation, efficient case management, straight talk, an even temperament, and above all, a focus on his clients’ legal objectives to assist in accomplishing their business goals. His recent experience in the senior leadership of the EPA makes him a trusted advisor and effective advocate for companies that are facing the high stakes of complex environmental enforcement matters, particularly under the CAA. Patrick’s clients also value his team-based approach to integrating business, technical, and legal disciplines to develop effective and innovative permitting and project development strategies. 

Prior to his service at the EPA, Patrick spent the first two decades of his legal career at a Global Top Ten law firm where clients relied on him to represent them in a variety of environmental enforcement cases, internal compliance investigations, and complex permitting matters.

With the combined experience of being one of the highest-ranking environmental enforcement attorneys in the federal government and over twenty years in private practice, Patrick has developed a unique skill set in the areas of civil environmental litigation, complex environmental permitting, and environmental enforcement investigations that makes him a trusted advisor to clients worldwide.

Experience Highlights

  • Represented a bulk chemicals terminal operator in Texas in a precedent-setting EPA enforcement case under the CAA
  • Represented a heavy-duty diesel engine manufacturer in Detroit in an EPA mobile source enforcement case under the CAA
  • Represented a coal-fired power plant owner in New Mexico in an EPA and citizen enforcement case under the CAA’s New Source Review program
  • Represented a surface coal mine operator in New Mexico in citizen suit cases under the Endangered Species Act (ESA), the Resource Conservation and Recovery Act (RCRA), and the Clean Water Act (CWA)
  • Represented an LNG exporter in securing environmental permits and approvals for 30 MTPA of LNG capacity

Environmental Enforcement Defense

  • Represented a West Virginia wind energy facility in a U.S. Fish & Wildlife Service (FWS) criminal enforcement case under the Migratory Bird Treaty Act
  • Represented a gas-fired power plant operator in Texas in an internal investigation under the CAA
  • Represented a chemical manufacturer in Texas in an internal investigation under the CAA
  • Represented a Wyoming wind facility in a U.S. FWS criminal investigation under the Bald & Golden Eagle Protection Act
  • Represented a Maryland wind facility in a citizen suit case under the ESA
  • Represented a surface coal mine operator in New Mexico in a citizen suit case under the National Environmental Policy Act
  • Represented an underground coal mine operator in New Mexico in a citizen suit case under RCRA
  • Represented a coal-fired power plant operator in North Dakota in an EPA and North Dakota enforcement case under the CAA
  • Represented importers of tropical hardwoods in citizen suit cases under the Convention for the Import of Threatened and Endangered Species
  • Represented numerous coal-fired power system operators across the country in EPA, state, and citizen suit enforcement cases under the CAA
  • Represented automobile and engine manufacturers in EPA enforcement cases under the CAA
  • Represented coal-fired power plant operators in judicial challenges to their CAA construction permits
  • Represented a pork processing company in Virginia in an EPA enforcement case under the CWA
  • Represented a hazardous waste disposal company in a CERCLA cost reimbursement action against EPA

Project Development and Permitting

  • Represented an energy company in a major expansion of its refining capacity in Texas by securing a PSD permit
  • Represented a chemical manufacturing company in obtaining a PSD permit that would allow the continued use of its on-site power island
  • Represented an oil company regarding its use of anthropogenic CO2 in enhanced oil recovery operations
  • Represented a fertilizer manufacturing company in obtaining a PSD permit that would allow for a major expansion of its manufacturing operations in the Midwest
  • Represented a major international mining company in the expansion of coal mines in the American Southwest, including evaluating climate change-related impacts of coal combustion
  • Represented an ammonia manufacturing company in obtaining a PSD permit that would allow for the construction of a major new facility on the Texas Gulf Coast
  • Represented a waste-to-energy facility in obtaining a PSD permit that would allow for the construction of a new unit in an eastern state


Contact Details

Washington

T +1.202.639.6734
F +1.202.879.8834
ptraylor@velaw.com
2200 Pennsylvania Avenue NW
Suite 500 West
Washington, DC 20037
Local time: 5:30 AM
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Patrick's Practices

  • The George Washington University Law School, LL.M, Environmental Law, 1996
  • South Texas College of Law, J.D. (Member, South Texas Law Review), 1994
  • Texas A&M University, B.A., History, 1991
  • Admitted to practice: District of Columbia; Texas; Supreme Court of the United States; U.S. Court of Appeals, D.C. Circuit; U.S. Court of Appeals, Tenth Circuit; U.S. District Court, District of Colorado; U.S. District Court, District of Columbia; U.S. District Court, District of North Dakota; U.S. District Court, Southern District of Texas
  • Deputy Assistant Administrator, U.S. Environmental Protection Agency, Office of Enforcement and Compliance Assurance, 2017–2019
  • Chambers USA, Environment (District of Columbia), 2012–2013
  • Selected to the Washington, DC Super Lawyers list, Super Lawyers® (Thomson Reuters), 2014–2015